Gujarat High Court

### REASSESSMENT NOTICE ISSUED BEYOND THE REMAINING LIMITATION PERIOD UNDER TOLA AND ASHISH AGARWAL IS TIME-BARRED

SONALBEN CHETANBHAI GADHIYA vs THE INCOME TAX OFFICER, WARD 3(3)(1), SURAT

Gujarat High CourtJUDGMENT: June 22, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner challenged an order passed under Section 148A(d) and a consequential notice issued under Section 148 of the Income Tax Act, 1961, dated 26.07.2022 for Assessment Year (AY) 2013-2014

Source reference: p. 1-2

Originally, a notice was issued on 25.06.2021 under the old regime during the extension granted by the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA)

Source reference: para. 3

Following the Supreme Court’s ruling in Ashish Agarwal, this notice was treated as a show-cause notice under Section 148A(b)

Source reference: para. 4

The Revenue provided information on 31.05.2022, and the Petitioner replied on 01.07.2022

Source reference: para. 7

The Assessing Officer subsequently issued the impugned reassessment notice on 26.07.2022

Source reference: para. 9
02

Issues

1. Whether the reassessment notice issued under Section 148 of the Income Tax Act on 26.07.2022 is time-barred and invalid based on the "surviving time" principle

Source reference: para. 2, 7
03

Law Applied

The court primarily applied the "surviving time" doctrine established by the Supreme Court in Union of India v. Rajeev Bansal [2024], which dictates that for a reassessment notice under the new regime to be valid, it must be issued within the balance of the limitation period surviving from the original TOLA extension

Source reference: para. 5, 9

Procedural directions from Union of India v. Ashish Agarwal regarding the transition of notices from the old regime to the new Section 148A framework

Source reference: para. 4

Dhanraj Govindram Kella v. ITO [2025], which calculated specific limitation deadlines for AY 2013-2014

Source reference: para. 6
04

Reasoning

The court analyzed the timeline to determine if the "surviving time" for limitation had lapsed. It noted that the original notice was issued on 25.06.2021, leaving a specific number of days remaining until the TOLA deadline of 30.06.2021

Source reference: para. 7

Calculating the stay of limitation during the Ashish Agarwal implementation process (from the date of information supply on 31.05.2022 plus the mandated response time), the court determined that the "surviving time" for the Revenue to issue the Section 148 notice expired on 17.07.2022

Source reference: para. 7

Since the respondent issued the impugned notice and order on 26.07.2022—nine days after the deadline—the court found the entire proceeding to be hit by limitation

Source reference: para. 9

The Revenue could not offer a counter-argument to these verified dates

Source reference: para. 8
05

Holding

The Court held that all notices issued beyond the "surviving period" are time-barred and invalid as per the mandatory guidelines set in Rajeev Bansal

The High Court allowed the writ petition and quashed the order dated 26.07.2022 passed under Section 148A(d) and the notice dated 26.07.2022 issued under Section 148, setting aside all subsequent reassessment proceedings

Source reference: para. 10
Gujarat High Court

Original Court PDF

SONALBEN CHETANBHAI GADHIYAvsTHE INCOME TAX OFFICER, WARD 3(3)(1), SURAT

Gujarat High Court · June 22, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment